ST CLAIR partners has created this Privacy Policy and Collection Statement
(together referred to as "this Privacy Policy ") in order to
demonstrate our firm’s commitment to privacy. The policy shows our
position and commitment to our clients, potential clients and our associates
in this matter.

ST CLAIR partners will update this privacy policy as
required. If it is changed, the changes will be posted on our website
www.stclairco.com.au so that
you are always aware of the type of information collected, how the information
may be used, and under what circumstances it may be disclosed by ST CLAIR
partners.

ST CLAIR partners does not sell, trade, rent, distribute
or share any of its information which it has collected within the ordinary
course of it business operations. We will not use or disclose your or
your entities ‘Personal Information’ collected by us for any
other purpose other than the primary purpose for which it was provided
or secondary related purposes in circumstances where you would reasonably
expect such use or disclosure or where you have consented to such disclosure.
Please note that if at any time ST CLAIR partners is required by law
to release information about you or your entity then you and your entity
must co-operate fully with ST CLAIR partners and also with the relevant
authorities.

We are bound by The Institute of Chartered Accountants
in Australia (ICAA) rules and regulations of professional conduct to make
certain information available for inspection by The Institute to ensure
ongoing compliance with their mandatory professional standards. This may
involve your or your entities ‘Personal Information.’ We will
seek your consent first should The Institute wish to undertake a quality
review of your or your entities personal records.

In the event that you cease to be a client of ST CLAIR
partners any of your or your entities ‘Personal Information’
will be retained and stored by the firm for the required time period to
comply with the legislative, regulatory and professional requirements,
following which time the information will be destroyed.

This Privacy Policy does not apply to acts or practices
of ST CLAIR partners that are directly related to employee records of
current or former employees.

2. WHAT INFORMATION DOES ST. CLAIR PARTNERS COLLECT?

ST. CLAIR partners collects information when you engage us for our services
so that we may provide you with business services / tax / audit / accounting
and other financial and business related services. ST CLAIR partners
collects information about you in a number of different ways:

(a) When you engage ST CLAIR partners for accounting,
tax, audit and other related business service purposes we collect:

Your dependants name, (any previous names) date and place of birth
and taxable income

If applicable your bank account details

Any other related information that is necessary for us to operate
effectively and efficiently

Any other information that enables us and is necessary for us to discharge
our duties, functions, activities as your accountant, auditor, advisers
and tax agents.

(b) When your entities engage ST CLAIR partners for accounting, auditing,
tax and other business services purpose we collect:

The entities tax file number

Date of incorporation

If applicable bank account details

Contact details of public officers

Types of income derived and deductions incurred

Any other related information that is necessary for us to operate
effectively and efficiently

Any other information that enables us and is necessary for us to discharge
our duties, functions, activities as your entities accountant, auditors,
advisers and tax agents.

(c) When you send ST CLAIR partners correspondence, e-mail(s) or facsimile(s),
we collect your and your entities addresses / fax numbers and any other
related information that is necessary for us to operate effectively and
efficiently and that enables us to discharge our duties, functions and
activities as your advisers and business colleagues.

3. WHAT HAPPENS IF YOU DO NOT PROVIDE THE INFORMATION?

ST CLAIR partners is required to discharge, satisfy and comply with various
procedural, regulatory, legislative and professional standards requirements
pursuant to:

The Income Tax Assessment Act

Taxation Administration Act

Australian Taxation Office’s regulations and procedural outlines

Corporations Act

Rules and Regulations of The Institute of Chartered Accountants in
Australia

Tax Agent standard practice and code of behaviour

Common law requirements

Other relative legislation.

In order to meet the rigid and high standards set by the above-mentioned
requirements if you elect not to or fail to provide us with information:

which we consider will compromise the standards set by the legislative
and any other applicable requirements and

will not enable us to provide you with appropriate advice / service

then we reserve the right to terminate our services with you and your
entities.

4. WHY DOES ST. CLAIR PARTNERS COLLECT THE INFORMATION
?

ST CLAIR partners collects information so that we may provide you or
your entities with business / tax / audit / accounting and other financial
and business related services. Specifically some of the services would
be –

Preparation of business activity statements and instalment activity
statements

Auditing of financial statements

Valuation of shares in company’s and valuation of business

Negotiation, acquisition or sale of business

Other financial and business work.

ST CLAIR partners also collects the addresses of attendees of our

small business seminar

motel seminar

restaurant and café seminar

and other seminars, workshops and group gatherings.

We have a practice of sending a complimentary ‘inhouse’
quarterly newsletter to our clients, associates and to the above-mentioned
seminar, workshop and group gathering attendees. If at any time you receive
material that you did not request or do not want to receive such material
any more, then kindly notify us.

5. HOW IS YOUR OR YOUR ENTITIES
INFORMATION SECURED?

ST CLAIR partners has security measures designed to protect against the
loss, misuse, unauthorised access and improper modification, alteration
or disclosure of the Information under its control. These security measures
are:

External security measures

Passwords and internal controls to all databases when logging onto
the system

Sophisticated backup procedures

Offsite secured storage facility

Data integrity measures

Standardised procedures in data collection, entry and retainment

Employment confidentiality agreements.

6. ACCESSING YOUR INFORMATION

You have the right to access the information held by us about you. If
any information is inaccurate, you have the right to request corrections.

7. CONTACTING

If you have any questions about this Privacy Policy, you should contact: